FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 1

Federal Railroad Administration

FINDING OF NO SIGNIFICANT IMPACT AND SECTION 4(f) DETERMINATION

Kellogg/Seminary Street Grade Separation Project:

Grade Crossing Mitigation

Knox County,

City of Galesburg, Illinois

July 2012

BACKGROUND

The Federal Highway Administration (FHWA) and the City of Galesburg, IL, prepared an 

Environmental Assessment (EA) for the Kellogg/Seminary Street Grade Separation Project

(Project) in compliance with the National Environmental Policy Act (NEPA) (42 U.S.C. § 4321 

et seq.). In accordance with 40 CFR § 1501.6 and the Federal Railroad Administration’s (FRA)

Procedures for Considering Environmental Impacts (64 FR 28545), FRA participated as a 

cooperating agency in the development of the EA for the Project. To fund this Project, the City 

of Galesburg received Federal contributions through an FY 10 Earmark that included $1,772,000 

from FHWA and $2,922,000 from FRA, under the Rail Line Relocation and Improvement 

Program. 

The FRA-funded portion of the Project would involve the construction of a grade separation over 

the Chillicothe Subdivision of the BNSF Railway (BNSF) at Kellogg and Seminary Streets

(Kellogg/Seminary Street) in the City of Galesburg, Knox County, IL (the City or Galesburg), 

including mechanically stabilized earth (MSE) retaining walls, roadway widening and 

reconstruction, aggregate column ground improvement, construction of a box culvert, storm 

sewer relocation, water main relocation, sanitary sewer relocation, concrete and brick sidewalks, 

concrete driveways, related collateral construction, and grade-crossing improvements for future 

Quiet Zone implementation. Additional costs for preliminary engineering, land acquisition, 

utility relocation, construction, and construction engineering are being funded separately by 

FHWA. 

BNSF currently operates freight trains through commercial and residential neighborhoods on an 

east-west double-track mainline that transects the City of Galesburg. This transcontinental route 

connects the Ports of Los Angeles and Long Beach, CA, to Chicago, IL, and is referred to as the 

Chillicothe Subdivision. In 2003, the City commissioned a rail corridor relocation study (2003 

Relocation Study) to explore options for redirecting train traffic on the Chillicothe Subdivision. 

In 2004, as many as 72 trains per day moved through Galesburg on the Chillicothe Subdivision,

and BNSF projected that number to increase to approximately 120 trains per day by 2015. As of 

2008, the number of trains moving through the City on the Chillicothe Subdivision had risen to 

96 trains per day.
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 2

Once the Project is completed, it will improve public access, public safety and emergency 

vehicle response times in the City by enabling the public and particularly emergency vehicles to 

access the other side of the Chillicothe Subdivision while it is occupied by a train. Through the 

alternatives analysis, a grade separation overpass/structure was determined to be the most 

reasonable approach to meet the purpose and need. The overpass would extend from the 

intersection of Seminary and Grove Streets on the north to the intersection of Kellogg and Water

Streets on the south, crossing mid-block, with additional roadway improvements between Water 

and Main Streets. 

STATEMENT OF PURPOSE AND NEED

Purpose

The primary purpose of the Project is to improve public access, as well as safety and emergency 

vehicle response in the City, by enabling vehicle access to both sides of the Chillicothe 

Subdivision while it is occupied by a train. 

Need

The high volume of trains on the Chillicothe Subdivision results in frequently blocked railroad 

crossings, which delay the public, as well as ambulance, police, and fire response vehicles

throughout the City, for up to 8 minutes at any one time. The Project will reduce traffic delay 

and congestion and will contribute to the City’s overall Quiet Zone strategy by building a grade 

separation overpass/structure at North Kellogg and North Seminary Streets. 

ALTERNATIVES

In the 2003 Relocation Study conducted by the City of Galesburg, comprehensive relocation of 

the rail corridor was preferred by the residents and businesses impacted by rail operations along 

the Chillicothe Subdivision. Because the 2003 Relocation Study found the estimated cost of rail 

line relocation was much higher than originally anticipated ($207-$329 million; 2003 dollars), a 

scaled-down alternative was included in the Study that focused on grade separations and 

institutional measures with the City. These measures included the construction of rail-street 

grade separations at strategic locations, which would alleviate emergency response delays and 

would also bring the City closer to implementing a Quiet Zone that would address quality-of-life 

issues caused by train horns blowing at each at-grade crossing.

Additional analysis of future traffic and rail operations in the 2003 Relocation Study identified 

three promising locations for grade separations: the Chillicothe Subdivision crossings at West 

Main Street and Seminary Street, and the Mendota Subdivision crossing at East Main Street. 

Subsequently, the City and FHWA determined that the potential grade separations identified in 

the 2003 Relocation Study would result in impacts to the Galesburg Historic District. 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 3

In an effort to avoid impacts to the Galesburg Historic District, two additional crossings of the 

Chillicothe Subdivision located outside of the historic district were considered. The additional 

crossings at Henderson Street and Lincoln Street are the only north-south arterial roadways 

outside of the Galesburg Historic District. 

In summary, the following alternatives were considered in the EA: 

Railroad Construction Alternatives

• Chillicothe Subdivision Relocation Alternative A

• Chillicothe Subdivision Relocation Alternative B

• Chillicothe Subdivision Relocation Alternative C

• Depression of the Chillicothe Subdivision through the City of Galesburg

• Mendota Subdivision Relocation Alternative

Roadway Construction Alternatives

• Overpasses of the Chillicothe Subdivision on:

o Seminary Street

o Kellogg Street

o Kellogg Street/Seminary Street

o Broad Street

o Cedar Street to Broad Street (which would connect East Water Street and West

Water Street)

o Henderson Street

o Lincoln Street

• Underpass of the Chillicothe Subdivision at Seminary Street

Institutional Alternatives

• Duplicate emergency facilities at strategic locations

• Implement a Quiet Zone

These alternatives were first evaluated on their ability to meet the purpose and need of the 

Project. If an alternative did not meet the defined purpose and need, it was eliminated from 

further study. Next, each of the remaining alternatives was evaluated considering engineering 

and environmental factors. Engineering factors included constructability, maintenance, and cost. 

Environmental factors considered included the impacts that would occur to biological resources, 

historic and cultural resources, as well as socioeconomic impacts, changes in noise and vibration 

levels, conversion of prime farmland, and impacts to wetland and streams. The alternatives were 

presented to the public for comment and input. 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 4

ALTERNATIVES ELIMINATED

Through the alternatives analysis process described in the EA, it was determined by the City and 

FHWA that several of the alternatives did not fully address the purpose and need and were, 

therefore, eliminated from further consideration. Several alternatives were also eliminated 

because of engineering constraints and environmental impacts.

Alternatives eliminated because of failure to meet purpose and need

Henderson Street Alternative: Henderson Street, located 1 mile west of Seminary Street, is the 

only arterial route outside of the Galesburg Historic District that does not have an existing grade 

separation at the Chillicothe Subdivision. This route intersects the Chillicothe Subdivision south 

of Main Street, outside of the Historic District. Because of its distance from the medical 

facilities and the central part of the City, a grade separation at this location will not improve 

emergency response times to the medical facilities and, therefore, does not meet the purpose and 

need of the Project. 

Lincoln Street Alternative: Lincoln Street is located 0.5 miles east of Seminary Street, runs 

parallel to the Mendota Subdivision at a northeasterly angle, and connects to U.S. Highway 35 

via Knox County Highway 9 on the northeast side of Galesburg. This roadway carries a 

relatively low volume of traffic compared with Henderson or Seminary Street. Lincoln Street 

intersects the Chillicothe Subdivision just south of Grove Street, outside of the Historic District. 

This alternative does not improve access to the medical facilities on Seminary Street because it 

still requires emergency vehicles to encounter the at-grade crossing of the Mendota Subdivision 

at East Main Street. This alternative does not adequately address the purpose and need for the 

Project. Furthermore, because Lincoln Street is adjacent and parallel to the Mendota 

Subdivision, the construction of an overpass at this location would require the closure of two 

existing underpasses at Losey and North Streets, which would increase congestion and response 

times of emergency vehicles in this area. 

Mendota Subdivision Relocation Alternative: The relocation of the Mendota Subdivision does 

not meet the purpose and need of the Project because it would not address emergency vehicle 

access, public safety, or the delays and congestion created by the Chillicothe Subdivision.

Broad Street Alternative: The estimated construction cost of the North Broad Street overpass 

alternative was comparable to other road construction alternatives, but would impact a greater 

number of commercial properties than other crossings. Traffic migration to Broad Street could 

result in an unacceptable level of service for this roadway. An overpass in a north-south 

orientation on Broad Street would improve the response time from the Central Fire Station and 

the Knox County/Galesburg Public Safety Building, but other emergency services may see 

limited improvement. This alternative would not result in meaningful changes in emergency 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 5

response times from the Seminary Street medical facilities and, therefore, does not meet the 

purpose and need.

Cedar Street to Broad Street Alternative: The North Cedar Street to North Broad Street overpass 

would result in adverse impacts to commercial, residential, and historic properties and would 

reduce existing parking lot capacity. As constructed, Cedar and Broad Streets do not carry large 

volumes of traffic within the City of Galesburg, so a grade separation at this location would also 

require future roadway capacity upgrades. In addition, this crossing would not meaningfully

improve emergency response times, as noted in the North Broad Street overpass alternative. 

Therefore, this alternative does not meet the purpose and need.

Alternatives eliminated because of engineering constraints and/or environmental impacts

Railroad Relocation Alternative A: This was the most favorable relocation alternative from the 

2003 Relocation Study. Alternative A would have the highest level of benefits for rail operations 

and for general traffic flow and safety; however, at nearly $329 million (2003 dollars), it is the 

most costly option and would consume the most acres of prime farmland. In addition, this 

alternative raises questions about how a large, independently functioning corridor could be

constructed in phases. For these reasons, this alternative was eliminated from further 

consideration.

Railroad Relocation Alternative B: This alternative from the 2003 Relocation Study would have 

improved through-corridor running times for trains by nearly 5 minutes per train and was less 

costly than Railroad Relocation Alternative A at $284 million (2003 dollars). However, this 

option would require several long cut sections 45-60 feet deep with some challenging 

construction and rail maintenance issues, including winter snow removal. In addition, this option

would consume a wide swath of land through the City’s proposed industrial park along U.S. 

Highway 150 at the southeast side of the City. For these reasons, this alternative was eliminated 

from further consideration.

Railroad Relocation Alternative C: This alternative from the 2003 Relocation Study was the 

least costly railroad relocation alternative at $207 million (2003 dollars). However, Alternative 

C would potentially impact Galesburg neighborhoods along the Mendota Subdivision with noise 

and diesel emissions and would impact BNSF operations with a net loss in through-corridor 

running times for trains. Also, this option would have the same challenging construction and rail 

maintenance issues as Alternative B with a required 2.5-mile cut section 45-60 feet deep. For 

these reasons, this alternative was eliminated from further consideration.

Depressing the Chillicothe Subdivision through the City of Galesburg: This alternative would 

eliminate train and traffic conflicts and delays for emergency services caused by train-occupied

railroad crossings. However, this option would result in greater impacts to the historic district
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 6

than any of the other build alternatives because of the land that would have to be acquired 

adjacent to the existing tracks. Also, it would have an extraordinarily high construction cost 

(because of the need for bridges at every roadway crossing), even under the assumption that 

some roadways would be closed to reduce the cost of crossings. In addition, emergency 

responders would need to avoid closed roads, worsening emergency response issues. Depressing

the Chillicothe Subdivision would also present engineering challenges that would add to the cost 

of this alternative. The Chillicothe Subdivision would be depressed below the grade of Cedar 

Creek, creating the need for pump stations to prevent drainage problems. For these reasons, the 

depression of the Chillicothe Subdivision was eliminated from further consideration.

Seminary Street Underpass: This alternative would be located on the same road as the medical 

services. This is expected to be the most costly and extensive option because of the extensive

underground construction issues, drainage implications to Cedar Creek, and its location within 

the Cedar Creek floodplain. The Seminary Street crossing is the low point of the existing 

roadway, and the proposed grade for the underpass roadway would be approximately 10 feet 

lower than Cedar Creek and therefore would require substantial continuous dewatering pumps to 

make the roadway passible. Furthermore, this option would require construction of a short 

section of temporary track (shoo-fly) to keep two railroad tracks in service at this location at all 

times, which is a requirement from BNSF. Construction of the shoo-fly would require 

acquisition of properties adjacent to the railroad track for two blocks east and west of the 

Seminary Street crossing. For these reasons, a Seminary Street underpass was eliminated from 

further consideration.

ALTERNATIVES CARRIED FORWARD

The alternatives carried forward for detailed environmental review included: 

Build Alternatives

• Overpasses of the Chillicothe Subdivision on:

o Kellogg Street

o Seminary Street

o Kellogg Street/Seminary Street (preferred alternative)

No-Build Alternative

• No action is taken.

Two build alternatives were developed during the EA process, and one build alternative was 

recommended in the City’s 2003 Relocation Study. The three alternatives were carried forward 

for detailed environmental evaluation along with the No-Build Alternative in the EA. Because 

of the build alternatives’ locations near the central part of the City, they all have a high 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 7

likelihood of satisfying the purpose and need and would improve public safety and improve 

emergency response (with the added benefit of improving traffic flow) at a lower relative cost. 

These build alternatives have fewer maintenance requirements and property impacts than the 

other ones considered and dismissed.

The three build alternatives are all similar in that they will all improve public safety and 

emergency service response times to some extent. Each will have impacts to 

residential/commercial properties, similar long-term maintenance costs, and impacts to the 

Galesburg Historic District because the build alternatives carried forward lie within the district’s 

boundaries. 

Kellogg and Seminary Streets are north-south roadways, located three and four blocks

(respectively) east of the Galesburg Public Square at the intersection of Broad and Main Streets. 

Each of the overpass alternatives has similar structural features. With any of the overpass 

alternatives, the structure would begin at Water Street and end at Grove Street. The overpass 

would start and end as a three-lane roadway. As the roadway rises to form the overpass, it 

transitions to a two-lane road with 14-foot lanes. Eight-foot-wide sidewalks are provided on 

both sides of the overpass. At the beginning and end of the overpass, the sidewalks taper to a 

width of 5 feet with variable width greenways between the backs of the curbs and sidewalks.

Study Area

Kellogg and Seminary Streets are within one city block of each other, and the Project study area 

was scaled down. The new study limits were reduced to the area extending from Losey Street on 

the north to Main Street (U.S. Highway 150) on the south and Kellogg Street on the west to 

Seminary Street on the east. 

Preferred Alternative

During the impact analysis of the alternatives, the City and FHWA identified the 

Kellogg/Seminary Street Overpass alternative as the preferred alternative. This selection was 

made largely because the other two overpass alternatives would have undesirable effects to the 

historic districts. In addition, this option has a low estimated cost of $16 million.

The preferred alternative involves the construction of a grade separation that crosses midblock 

between the intersection of Seminary and Grove Streets on the north and the intersection of 

Kellogg and Water Streets on the south. Additional roadway improvements within the existing 

right-of-way would be made on Kellogg Street between Water and Main Streets. Seminary 

Street is currently a two-lane urban arterial with parking on both sides from Losey Street to Main 

Street. The existing at-grade crossing is located approximately 100 feet north of the 

Seminary/North Street intersection. There are traffic signals at Seminary’s intersection with 

Losey and Main Streets. All other intersections between these signals are two-way stops

controlled with preference given to Seminary Street.
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Kellogg is a two-lane urban collector road with parking on both sides from Losey Street to Main 

Street. The existing at-grade crossing is located approximately 100 feet south of the 

Kellogg/North Street intersection. As part of the Project, intersection improvements to all legs of 

the Kellogg/Main Street intersection would be necessary to facilitate the larger trucks and 

additional traffic moving to Kellogg Street. Traffic controls would remain unchanged except at 

the intersection of Seminary and North Streets, which would become a two-way stop controlled 

intersection with North Street having the right-of-way.

ENVIRONMENTAL CONSEQUENCES

The EA describes the existing conditions in the Project area and the potential impacts and 

mitigation that would result if the preferred alternative is implemented. Information was 

gathered from various sources, including site observations, maps, aerial photography, and local, 

State, and Federal agency data.

The following environmental factors were analyzed and recorded for the three build alternatives

and the No-Build alternative to identify environmental impacts and to help in the identification 

of the preferred alternative:

• Historic and Cultural Resources

• Section 4(f) 

• Socioeconomics

• Residences and Commercial Businesses

• Environmental Justice

• Emergency Service Response

• Travel Patterns

• Construction

• Water Resources

o Surface Water

o Groundwater

o Floodplains

• Air Quality

• Noise and Vibration 

• Special Waste
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 9

The following environmental factors were analyzed, and no impacts were recorded for the three 

build alternatives that include Kellogg, Seminary, or Kellogg/Seminary Streets and the No-Build

alternative:

• Agricultural

• Archeological Sites

• Energy

• Natural Resources

• Groundwater/Quality

• Wetlands

• Section 6(f)

• Open Space Lands Acquisition and Development Act Lands

• Threatened and Endangered Species

Historic and Cultural Resources

The preferred alternative would extend from the intersection of Seminary and Grove Streets on 

the north to the intersection of Kellogg and Water Streets on the south, crossing midblock, with 

additional roadway improvements between Water and Main Streets. The Area of Potential 

Effect for Section 106 purposes is defined as the boundaries of the Galesburg Historic District.

The Project study area is entirely within the Galesburg Historic District. Contributing resources

to the Galesburg Historic District would be directly and indirectly impacted by the proposed 

Project. The historic survey report identifies 52 properties contributing to the historic district 

within the study area. Twenty-four contributing properties would be affected by the preferred 

alternative. Sixteen contributing structures would be acquired, permanent right-of-way

acquisition of part of three properties with contributing structures would be required, and 

temporary easements would be required from five properties with contributing structures. 

Sixteen residential properties and three commercial properties would be displaced. Two of the 

three commercial properties are currently vacant. A total of 4.097 acres will be taken from the

historic district, 2.781 of which are from contributing properties.

Because there are no feasible avoidance alternatives that meet the Project purpose and need, 

minimization measures were identified. The minimization measures outlined below were 

developed through coordination with the Illinois Historic Preservation Agency (IHPA), the 

Galesburg Historical Society, and the Galesburg Local Commission (GLC). The overpass 

structure would be placed on MSE walls, rather than conventional embankments. The use of 

MSE technology reduces the Project footprint by over 50%, reducing the need for additional 

right-of-way and the need to remove additional structures within the historic district. Brick 

sidewalks and stone curbing would be replaced where appropriate. Any salvageable materials 

removed would be stored for use in the City’s ongoing brick street maintenance program. 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 10

Removed landscaping on properties with temporary easements would be replaced after 

construction activities are completed. Impacted trees would be replaced by the City in 

accordance with the Illinois Department of Transportation (IDOT) policy. The locations and 

species mix of replacement trees would be coordinated with property owners and GLC. Section 

106 mitigation commitments are listed in a Memorandum of Agreement (MOA) among the 

IHPA, FHWA, IDOT, and the City and are included as an attachment to this Finding of No 

Significant Impact (FONSI).

Section 4(f)

Section 4(f) of the U.S. Department of Transportation Act (DOT Act) of 1966 (49 U.S.C. 303) 

states that both FRA and FHWA cannot approve the use of land from publicly owned parks, 

recreational areas, wildlife, and waterfowl refuges or public and private historic sites unless the 

following conditions apply: (1) There is no feasible and prudent alternative to the use of the 

property; and (2) the action includes all possible planning to minimize harm to the property 

resulting from use. Evaluation of the Project has determined that all of the build alternatives 

would result in the “use” of Section 4(f) resources. 

A variety of alternatives were evaluated in the EA in an attempt to meet the purpose and need of 

the proposed Project and to minimize Section 4(f) impacts. Four alternatives (No-Action, 

Mendota Subdivision relocation, emergency facility duplication, and implementation of a quiet 

zone) were determined inadequate. Four other alternatives (Henderson Street overpass, Lincoln 

Street overpass, relocation of Chillicothe Subdivision, and depression of Chillicothe Subdivision) 

were found to serve the Project’s purpose and need but were not feasible and prudent solutions. 

The remaining three alternatives meet the purpose and need for the Project, but each has impacts 

to Section 4(f) resources. Therefore, there is no feasible and prudent alternative that avoids the 

use of the Section 4(f) resource. FHWA may only approve the alternative that causes the least 

overall harm. As described above, the 4(f) resource impacted by this Project is the Galesburg 

Historic District and the contributing properties within it. On the basis of the environmental 

review process, the Kellogg/Seminary Street alignment would result in the least harm to Section 

4(f) resources as discussed in the Final Section 4(f) determination attached to this FONSI. 

The individual Section 106/4(f) evaluation was coordinated with the Department of Interior, the 

Advisory Council Historic Preservation (ACHP), and the Illinois State Historic Preservation 

Officer (IL SHPO). The public was also given an opportunity to comment through a public 

notice published on March 31, 2011. No comments were received during the public comment 

period. 

A Section 106 MOA was executed among FHWA, IDOT, IL SHPO, and the City. The 

Galesburg Landmark Commission (GLC) was invited to be a concurring party to the MOA and 

signed the MOA on November 1, 2011. Pursuant to 36 CFR § 800.2(a)(2), FRA has designated 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 11

FHWA as the lead Federal agency to carry out the agreement for the undertaking, satisfying 

FRA’s Section 106 obligation. FRA concurs with the MOA evidencing that FHWA has 

complied with Section 106 and its implementing regulations at 36 CFR Part 800, that FHWA has 

taken into account the effects of this Project on historic properties, and that FHWA has 

committed to ensuring that certain measures are conducted. FRA’s actions, with respect to the 

Project will also be undertaken, in manner that is consistent with the MOA. 

The Kellogg/Seminary Street-preferred alternative, while impacting a greater number of

contributing properties, converts the least amount of acreage of contributing properties to 

transportation use. The proposed Project includes all possible planning to minimize harm to 

such properties, as described above and in the Environmental Commitments section of this 

document.

Socioeconomics

Consideration of effects to the social and economic environment include: an assessment of the 

community characteristics and cohesion, protected groups of people, environmental justice, 

public facilities and services, changes in travel patterns, relocations of residences or businesses, 

economic impacts, land use, growth and economic development, and changes to pedestrian or 

bicycle facilities.

Community Characteristics and Cohesion

The preferred Kellogg/Seminary Street alignment passes through a mixed commercial 

and residential area. Modern office and commercial buildings are interspersed with 

homes. The north portion of the alignment ties into Seminary Street, which is an arterial 

roadway. The south portion of the alignment ties into Kellogg Street, which has a lower

volume of traffic but is still part of the commercial downtown area. Some of the 

landscaping features, such as brick streets or large, old landscaping trees associated with 

other areas in the Historic District, have been replaced by more modern materials, such as 

asphalt and young trees representing a variety of species. Stretches of brick sidewalk and 

sandstone curbing have remained intact over time.

No unique community groups were identified during the EA process, but construction of 

the overpass will result in a minimal loss of community cohesion. The presence of the 

Chillicothe Subdivision and Cedar Creek already fragment the neighborhood to some 

degree both visually and spatially. Because the Kellogg/Seminary Street overpass 

stretches between the two streets, the overpass would lie between Cedar Creek and the 

Chillicothe Subdivision and, therefore, would not further compound the fragmentation of 

the neighborhood. In terms of mobility, community cohesion would remain much the 

same. The sidewalks, provided on each side of the overpass structure, would provide a 

safer travel route for pedestrians. The overpass would create a visual barrier to the 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 12

adjacent residences in the neighborhood. However, the Project would be designed to 

minimize visual impacts to the extent possible by incorporating elements that 

complement the surrounding Historic District, such as period lighting and fencing, and by 

providing landscaping around the structure.

Environmental Justice

Executive Order 12898 on Environmental Justice addresses disproportionately high and 

adverse impacts to minority or low-income populations from federally funded Projects. 

Environmental justice is the fair treatment and meaningful involvement of all people 

regardless of race, color, national origin, or income with respect to the development, 

implementation, and enforcement of environmental laws, regulations, and policies.

The Project area is racially mixed, and household income and poverty level vary between 

the census blocks that make up the study area. Information about the demographics of 

the Project area was obtained from the U.S. Census Bureau from the 2000 and 2010 

decennial census.

Because of the relatively small size of the Project area, data was reviewed at the block 

group level, the smallest statistical area for which data is available. This data was 

compared to demographic data for the entire City for the same year. The 2010 data set 

describing low-income populations was not available during the environmental analysis.

Therefore, data from the 2000 census is presented for low-income populations. 

According to the 2010 census, minority groups make up 18.9% of Galesburg’s 

population. Affected Block Groups 1 of Census Tract 8 and 6 of Census Tract 3 have a 

higher minority population than the City of Galesburg at 23.2 and 20.3%, respectively. 

In addition, the 2000 census records show that 10.7% of the population of Galesburg was 

living below the poverty level. Affected Block Groups 4 of Census Tract 6, 1 of Census 

Tract 8, and 5 of Census Tract 3 have a higher percentage of low-income families than 

the City of Galesburg at, 24.7, 15.7, and 11.3%, respectively. There were no

disproportionate impacts identified to low-income or minority populations from any of 

the build alternatives that include Kellogg, Seminary, or Kellogg/Seminary Streets. FRA 

finds that because no adverse environmental justice impacts are expected to occur as a 

result of the Project, no mitigation is necessary.

Emergency Service Response

Adverse impacts are not expected to occur to emergency service response as a result of 

the Project. In fact, the primary goal of the proposed Project is to improve emergency 

response times, specifically ambulance response times south of the Chillicothe 

Subdivision and police and fire response times north of the Chillicothe Subdivision. The 

preferred alternative would improve emergency response times. Kellogg Street would 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 13

connect to Seminary Street, effectively becoming part of the arterial roadway and 

providing direct access from the medical facilities to the area south of the Chillicothe 

Subdivision. FRA finds that because no adverse impacts to emergency services are 

expected to occur as a result of the Project, no mitigation is necessary.

Travel Patterns and Traffic Operations

Projected traffic patterns were estimated based on growth rates and estimated redistribution of

traffic adjacent to the Project area. Traffic studies were performed during peak travel periods, 

7-9 a.m. and 4-6 p.m., to capture the maximum traffic volumes from streets in the Project area 

and the movement of the traffic.

Within the study area, traffic signals are located at Seminary Street’s intersections with Losey 

and Main Streets. The intersections of Seminary Street with Ferris, Water, North, Peck, and 

Grove Streets are stop controlled, with preference given to Seminary Street. A traffic signal is 

located at Kellogg Street’s intersection with Main Street. The intersections of Kellogg Street 

with Ferris, Water, and Grove Street are two-way stop controlled (TWSC), with preference given 

to Kellogg Street. The intersection of Kellogg Street with North Street is a four-way stop 

controlled (AWSC) intersection. The intersection of Kellogg Street with Losey Street is a 

TWSC intersection with preference given to Losey. 

Because of the angled design of the preferred alternative, Seminary and Kellogg Streets would 

no longer be through streets. Kellogg Street would be closed between North and Water Streets. 

Seminary Street would be closed between Peck and North Streets. These closures would 

eliminate two at-grade railroad crossings on the Chillicothe Subdivision. All other portions of 

Kellogg and Seminary Streets would remain open. The intersection of Peck and Seminary 

Streets would be closed. As part of a separate Project, the City of Galesburg has proposed to 

close a section of South Seminary Street at its intersection with South Street within the next 10

years. Kellogg Street would become the arterial roadway between Main and South Streets.

Construction of the grade separation may result in heavier usage of Kellogg Street (between 

Water and Main Streets) and Seminary Street (north of Grove Street). Traffic volumes would 

likely increase as motorists use the grade separation to avoid other nearby at-grade crossings. 

Collector roads may also experience heavier traffic volumes. Traffic volumes are expected to 

increase on Kellogg Street between Water and South Streets. The traffic on Seminary Street 

south of the railroad tracks is expected to be lighter after the grade separation is constructed. The 

businesses located on Seminary Street south of the tracks would have less drive-by traffic, but 

they are more destination-type businesses, with clientele that specifically travels to the store, and 

are not expected to be negatively impacted by the reduction in traffic on the street. 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 14

FRA finds that because no adverse impacts to travel patterns or traffic operations are expected to 

occur as a result of the Project, no mitigation is necessary.

Water Resources

The Project area contains three water resources: Surface Water, Groundwater, and Floodplains. 

The proposed overpass would not result in permanent impacts to Cedar Creek, which is located 

within the Project area. However, the Project would require construction within Cedar Creek,

including removal of an existing bridge structure. The existing concrete lining within Cedar 

Creek would be removed and replaced during the installation of the double box culvert within 

the proposed overpass. Construction activities may lead to temporary water-quality impacts. 

Construction activities disturb soil, making it susceptible to erosion. Storm events can remove 

soil and deposit it into surface waters, a process known as sedimentation. Sediment is the 

primary pollutant associated with construction sites. In addition, stormwater can carry trash, 

debris, oil, grease, pesticides, and other contaminants, depositing them directly into surface 

waters. Sediment and pollutants can be detrimental to water quality, wildlife habitat, and human 

health. However, since the Project area is urbanized and storm drains and sewers are present, 

most surficial runoff will be controlled by the storm sewer system. This Project would not create 

any new potential routes or any new potential sources for groundwater pollution as defined in the 

Illinois Environmental Protection Act (415 ILCS 5/3, et seq.). Accordingly, the Project is not 

subject to compliance with the minimum setback requirements for community water supply 

wells or other potable water supply wells as set forth in 415 ILCS 5/14, et seq.

FRA finds that no adverse impacts to water resources are expected to occur as a result of the 

Project provided that best practices and applicable permit conditions, as outlined in the 

Environmental Commitments section (below), are followed.

Air Quality

The National Ambient Air Quality Standards (NAAQS), established by the U.S. Environmental 

Protection Agency (U.S. EPA), set maximum allowable concentration limits for six criteria air 

pollutants. Areas in which air pollution levels persistently exceed the NAAQS may be 

designated as “nonattainment.” States in which a nonattainment area is located must develop 

and put into practice a State Implementation Plan containing policies and regulations that will 

bring about attainment of the NAAQS. 

No portion of this Project is located within a designated nonattainment area. Accordingly, a 

conformity determination under 40 CFR Part 93 (“Determining Conformity of Federal Actions to 

State and Federal Implementation Plans”) is not required. Dust and particulate emissions can 

occur during building demolition, ground clearing, site preparation, grading, stockpiling of 

materials, on-site movement of equipment, and transportation of materials. The potential for 

particulate emissions is greatest during dry periods, periods of intense construction activity, and 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 15

during high wind conditions. If the appropriate measures to limit dust emissions during 

construction are taken, the Project will not cause any short-term particulate matter air-quality 

impacts. 

In addition to the criteria air pollutants for which there are NAAQS, U.S. EPA also regulates air 

toxics. Mobile Source Air Toxics are those pollutants that are known or suspected to cause 

cancer or other serious health effects, such as reproductive effects or birth defects, or adverse 

environmental effects. Many air toxics originate from human-made sources, including on-road 

mobile sources, non-road mobile sources (such as airplanes or locomotives), and stationary 

sources (such as factories or refineries). IDOT completed a Pre-Screen CO analysis for the 

proposed Project at the intersection of U.S. Highway 150 (West Main Street) and Kellogg Street. 

The results from this proposed roadway improvement indicate that a CO Screen for Intersection 

Modeling air-quality analysis is not required, because the data for the worst-case receptor is

below the 8-hour average NAAQS for CO of 9.0 parts per million, which is necessary to protect 

the public’s health and welfare. No permanent air-quality impacts are expected to occur as a 

result of the Project. 

FRA finds that no adverse impacts to air quality are expected to occur as a result of the Project

provided that best practices and applicable permit conditions, as outlined in the Environmental 

Commitments section (below), are followed.

Noise and Vibration Levels

Noise and vibration effects to receptors considered sensitive were evaluated, including effects to: 

residences, hotels/motels, hospitals, retirement communities, schools, parks, cemeteries, and 

other similar land use areas. Because of the grade-crossing closure, rerouting and elevation of 

traffic under the preferred alternative, noise and vibration levels decrease between the no-build 

and preferred alternative at many locations. Even with the increased traffic expected in the 20-

year projection, the noise levels generated by the preferred alternative do not approach or exceed 

the Noise Abatement Criteria at any location and do not exceed the existing levels by greater 

than 14 dBA. Therefore, with the absence of noise or vibration impacts, abatement does not need 

to be considered. Under the preferred alternative, noise and vibration levels are predicted to be 

lower than without the grade separation. The reduction in train and traffic noise and vibration is 

expected to benefit historic properties in this area for residential use and lead to long-term 

benefits to the historic district.

FRA finds that no adverse noise or vibration impacts are expected to occur as a result of the 

Project provided that best practices and applicable permit conditions, as outlined in the 

Environmental Commitments section (below), are followed.
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 16

Special Waste

Special waste, as defined by the Illinois Environmental Protection Agency (IEPA, 415 ILCS 

5/3.45) and used by IDOT, means any of the following:

• potentially infectious medical waste;

• hazardous waste, as determined in conformance with Resource Conservation and

Recovery Act hazardous waste determination requirements set forth in 35 Ill.

Admin. Code 722.111; and

• industrial process waste or pollution control waste, subject to certain exceptions.

Two Preliminary Environmental Site Assessments (PESAs) were conducted by the Illinois State 

Geological Survey (ISGS) for the Project area. ISGS PESA #1721 was completed May 22, 

2008. ISGS PESA #1721A was completed November 19, 2009. Each assessment included a 

review of the past uses of the properties adjacent to Seminary and Kellogg Streets, review of 

databases maintained by U.S. EPA and IEPA for regulated sites, and site observations. The 2008 

PESA included subsurface soil borings.

On the basis of the PESAs, FRA finds that no adverse impacts from special waste are expected to 

occur as a result of the Project have provided that best practices and applicable permit 

conditions, as outlined in the Environmental Commitments section (below), are followed.

COMMENTS AND COORDINATION

During preparation of the EA, early coordination and consultation was initiated with agencies, 

stakeholder groups, and the public to incorporate their comments and concerns into the 

development and analysis of the Project purpose and need, alternatives, and potential resultant 

environmental impacts. Public coordination included stakeholder meetings, briefings, and 

presentations and are detailed in the EA. An open-house public hearing was held about the 

completed EA on April 17, 2012 from 4 to 7 p.m. at City Hall in Galesburg, IL. Approximately 

57 individuals signed the attendance sheet. All comments received were considered, addressed, 

and responded to by the City. 

ENVIRONMENTAL COMMITMENTS

Applicable Regulations and Permits

The Kellogg/Seminary Street Overpass is the selected alternative. It was chosen after the 

potential impacts were evaluated, and the ability to mitigate impacts was considered for each of 

the alternatives. The following Federal regulations, statutes, and orders apply to this Project:

• Clean Water Act of 1977 (33 USC § 1251-1376)

• Endangered Species Act (50 CFR 17)

• Executive Order 11988, Floodplain Management (42 Federal Register [FR] 26951)

• Executive Order 11990, Protection of Wetland (42 FR 26961)
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 17

• Executive Order 12898, Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations (59 FR 7629)

• Executive Order 13166, Improving Access to Services for Persons with Limited English

Proficiency (65 FR 50121)

• Federal Railroad Administration Procedures for Considering Environmental Impacts (64 FR

28545)

• National Environmental Policy Act of 1969 (42 USC § 4321 et seq.)

• Regulations for Implementing the Procedural Provisions of the National Environmental

Policy Act (40 CFR 1500–1508)

• Section 4(f) of the U.S. Department of Transportation Act of 1966 (49 USC § 303)

• Section 6(f) of the Land and Water Conservation Act of 1965 (16 USC § 460)

• Section 106 of the National Historic Preservation Act, as amended (16 USC § 470)

• Section 404 of the Federal Water Pollution Control Act (33 USC § 1344)

• Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as

amended (42 USC § 61)

• Use of Locomotive Horns at Highway-Rail Grade Crossings, Final Rule (40 CFR 222 and

229)

Mitigation

Mitigation describes any action taken to reduce the adverse effects of potential impacts. This can 

include: 

• avoiding the impact altogether by not taking a certain action or parts of an action; 

• minimizing impacts by limiting the degree or magnitude of the action and its 

implementation; rectifying the impact by repairing, rehabilitating, or restoring the affected 

environment;

• reducing or eliminating the impact over time by preservation and maintenance operations

during the life of the action; and

• compensating for adverse impacts by replacing or providing substitute resources or

environments.

Historic and Cultural Resources

The following Section 106 mitigation commitments are listed in an MOA among the IHPA, 

FHWA, IDOT, and City of Galesburg: 

• The City will make the structure at 234-236 North Kellogg Street available for purchase and 

relocation. The purchaser would be required to execute a restrictive preservation covenant 

and rehabilitate the building in accordance with the Secretary of the Interior’s “Standards for 

Rehabilitation and Guidelines for Rehabilitating Historic Buildings.” If the structure is not 

purchased under these terms, the City may sell without restrictions or demolish the structure.
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 18

Prior to sale without a covenant or demolition of the structure at 234-236 North Kellogg

Street, the City shall document the property in accordance with Level III of the Illinois

Historic Buildings Survey.

• The City, in consultation with the GLC, shall ensure that a plan for salvage and reuse of 

architectural elements from the buildings within the Galesburg Historic District is agreed 

upon, submitted to IHPA for approval, and then implemented. This will provide residents of 

the historic district the opportunity to use with appropriate salvaged materials to restore

historic buildings throughout the district.

• The City shall ensure that the comments of the GLC are taken into account during Project 

design and shall incorporate historic design elements into the overpass and associated 

landscape features. These features shall include, but not be limited to, the overpass itself, 

sidewalks, trees, lighting, and fencing.

• The City shall undertake a building-by-building resurvey of structures within a portion of the 

Galesburg Historic District delineated as agreed to with the GLC. The survey will include 

the unsurveyed portions of the historic district generally located west of West Street, east of 

Grove Street, and a few properties at the northern edge of the district. This survey shall be 

completed within 2 years of the conclusion of the NEPA process and will be performed by a 

person familiar with State survey standards and guidelines who meets the professional 

qualifications outlined by the National Park Service in 36 CFR Part 61.

• The potential for archeological deposits will be investigated by IDOT and IHPA, and a plan 

will be developed for the recovery of any affected significant archeological deposits 

following property acquisition.

Section 4(f)

All possible planning to minimize harm to the Section 4(f) resource has been incorporated into 

the following commitments:

• Impacts to historic resources have been minimized to the extent possible by placing the 

proposed overpass on MSE walls, rather than conventional embankment. 

• Removed landscaping on properties with temporary easements will be replaced after 

construction activities are completed. Impacted trees will be replaced by the City of 

Galesburg in accordance with IDOT policy LEN-14. 

• The locations and species mix of replacement trees will be coordinated with property owners 

and GLC. 

• Brick sidewalks and stone curbing will be replaced where appropriate. Any remaining 

salvageable materials will be stored for use in the City’s ongoing brick street maintenance 

program.

• Intersections will be improved to handle the additional traffic and enhance traffic flow. 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 19

Residences and Commercial Businesses

The Uniform Relocation Assistance and Real Property Acquisition Policies Act and the IDOT 

Land Acquisition Procedures Manual will be followed for all displaced residents and businesses. 

Comparable housing is available in the Galesburg area for displaced residents. All housing 

resources are available to all displaced persons, without discrimination. The City will provide 

housing if needed. Commercial properties are available within the City for displaced commercial 

businesses. Temporary impacts will be limited to landscaping disturbance. After completion of 

construction activities, landscaping features will be returned to match their prior condition.

Water Quality

During the construction process, susceptibility to erosion will be increased because of the 

temporary reduction in vegetation as a result of excavation and embankment operations. IDOT’s 

Standard Specifications for Road and Bridge Construction includes provisions on erosion 

control. To reduce erosion of soils and subsequent sedimentation within Cedar Creek caused by 

construction activities, multiple erosion control strategies will be used. Perimeter erosion barrier 

and erosion control blanket installation is expected to reduce erosion of exposed soils. 

Temporary ditch checks and ditch linings may also be present to intercept eroded material prior 

to entrance into streams. The locations and specifications for erosion control measures for 

construction of the Project improvements will be included in the Project construction plans and 

specifications.

Permits will be required from numerous Federal agencies including a National Pollutant 

Discharge Elimination System permit, a U.S. Army Corps of Engineers permit under Section 404 

of the Clean Water Act and a Construction in Floodways, Rivers, Lakes and Streams permit from 

the Illinois Department of Natural Resources.

Air-Quality and Construction Emissions

The IDOT Standard Specifications for Road and Bridge Construction include provisions on dust 

control. Under these provisions, dust and airborne dirt generated by construction activities will 

be controlled through dust control procedures or a specific dust control plan, when warranted. 

The contractor and the City will meet to review the nature and extent of dust-generating 

activities and will cooperatively develop specific types of control techniques appropriate to the 

specific situation based on IDOT standards. Techniques that may warrant consideration include 

minimizing track-out of soil onto nearby publicly traveled roads, reducing speed on unpaved 

roads, covering haul vehicles, and applying chemical dust suppressants or water to exposed 

surfaces, particularly those on which construction vehicles travel. 

Temporary air-quality impacts are likely to occur with any of the three construction alternatives. 

Demolition and construction activities can result in short-term increases in fugitive dust and 

equipment-related particulate emissions in and around the Project area. Equipment-related 
FINDING OF NO SIGNIFICANT IMPACT and SECTION 4(F) DETERMINATION Page 20

particulate emissions are minimized if the equipment is well maintained. The potential airquality impacts would be short term, occurring only while demolition and construction work is in 

progress and local conditions are appropriate.

Noise and Vibration Levels

Trucks and machinery used for construction produce noise that may affect some land uses and 

activities during the construction period. The Galesburg Historic District and residents along the 

alignment will, at some time, experience perceptible construction noise from implementation of 

the Project. To minimize or eliminate the effect of construction noise on local receptors, 

mitigation measures have been incorporated into the IDOT Standard Specifications for Road and 

Bridge Construction as Article 107.35. The presence of the grade separation will allow the City 

to petition FRA and the Interstate Commerce Commission for a Quiet Zone, which would 

eliminate the requirement for train horn blowing where trains previously intersected Kellogg and 

Seminary Streets. 

Special Waste

Special waste issues will be managed in accordance with IDOT Standard Specifications for Road 

and Bridge Construction and Supplemental Specifications and Recurring Special Provisions. 

Each of the affected properties containing the recognized environmental conditions (RECs) is a 

total acquisition and, therefore, ineligible to be risk managed, according to IDOT BDE Chapter 

27, Section 2.05(a). In accordance with IDOT Departmental Policy LEN-13 (D&E-11) 

Identifying and Responding to Regulated Substances in Highway Project Development, a 

Preliminary Site Investigation will be performed at each property containing a REC to determine 

the nature and extent of the waste present, prior to the purchase of property and construction 

activities. The City will manage and dispose of contaminated materials in accordance with 

applicable Federal and State regulations and in a manner that will protect human health and the 

environment.